1.2 For the purposes of this policy “AltitudeCard.com” means Club Sun Limited.
(a) AltitudeCard.com’s general privacy terms that apply to all our dealings with you in any capacity; and
(b) additional privacy terms that are specific to this web site, which can be found below in the section headed “additional privacy terms for this web site”.
2. What information do we collect about you?
The personal information we collect about you is made up from the information you and others give us during your time as a AltitudeCard.com member. This includes information obtained through: your completion and submission of our application forms (including our AltitudeCard.com membership application form); your use of our web sites and services; and our communications with you.
- first name(s), surname
- address (street, street number, postal code, city and country/region)
- email address
- age range
- telephone and mobile number
- We may also monitor, record, store and use any telephone, email or other electronic communications with you for training purposes so that we can check any instructions given to us and to improve the quality of our customer service.
- Any personal data we collect from you will not be transferred outside the European Economic Area.
3. What about sensitive information?
We do not generally seek to collect sensitive personal information about our members. If we do seek to collect sensitive information we will ask you to explicitly consent to our proposed uses of that information at the time of collection. We use the term “sensitive personal information” to mean information about topics such as personality and private life, racial or ethnic origin, colour, membership of political parties or movements, or other such sensitive topics.
4. Can you give us information about another person?
In certain circumstances you may give us information about another person, for example as part of our “recommend a friend” scheme. If you give us information about another person then we accept it on the understanding from you that you have made the other person aware of how we will use and disclose their information and the other person has given you permission to provide their details to us. You should not provide us with others’ personal information if this is not the case.
OUR USE OF YOUR INFORMATION
5. How do we use your information?
5.1 We will use your information for the following main purposes: (a) for administration of your membership; (b) to provide you with our web sites and services as part of your membership benefits; (c) for membership communications; (d) for marketing purposes in accordance with your preferences (please see below for further details); (e) for internal analysis and research; (f) to comply with legal and regulatory requirements; and (g) to help detect and deal with crime and unsavoury behaviour.
5.2 We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
6. Do we use your information for marketing purposes?
6.1 We hate unsolicited marketing (such as spam emails) as much as you, which means we will not market our (or others) goods or services to you, nor give your information to third parties to allow them to market their goods and services to you, without your express consent.
6.2 You tell us your preferences regarding marketing communications as part of the AltitudeCard.com membership application and web site registration process. And you need not worry, if later, you change your mind since you can let us know of changes you wish to make to your marketing preferences at any time and we will update our records accordingly.
6.3 When making your decision about your marketing preferences, please remember that one of the main benefits of AltitudeCard.com membership is the fantastic offers we can provide to our members. We can only provide you with these offers with your permission, which is why we encourage you to take advantage of these fantastic offers by allowing us and carefully selected third parties to keep you informed of the latest deals.
7. How long will the data be stored for?
Where possible, AltitudeCard.com will take steps to erase any personal data that is no longer necessary for the purposes for which it is collected or otherwise processed, or if you have withdrawn consent for it’s processing and retention.
As a general rule, if you enter into or took steps to enter into a contract with AltitudeCard.com, we will store the data for a period of six years for compliance with our general legal obligations and for the exercise or defence of any legal claims.
Under the GDPR, you have the right to ‘block’ or request the deletion or removal of personal data to prevent further processing. This right to erasure is also known as ‘the right to be forgotten’. Specific circumstances in which you can request the deletion or removal of personal data includes:
- Where the personal data is no longer necessary for the purposes for which it is collected or otherwise processed
- Where you withdraw consent
- When you object to the processing and there is no overriding legitimate interest for continuing the processing
- Where the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
- Where the personal data has to be erased in order to comply with a legal obligation
- In case a deletion is not possible due to legal,statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the data will be blocked instead of deleted.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
8. Are we concerned about keeping your information secure?
We take security issues seriously. We have implemented appropriate steps to help maintain the security of our information systems and processes and prevent the accidental destruction, loss or unauthorised disclosure of the information we collect.
In order to protect the personal data collected from you by AltitudeCard.com against accidental or deliberate manipulation, loss, destruction or the access of unauthorised persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees,subcontractors and other support staff are obligated to observe confidentiality and data privacy.
Any access to your data that is stored at our company only takes place through an encrypted connection. Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognise that your use of the Internet and our website is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.
All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorisation.
9. To whom may we disclose your information?
9.1 We use agents and service providers (some of which may be located outside Europe) to collect,hold and process on our behalf your personal information for the purposes set out in this policy. These agents and service providers act on our instructions and will only use your information as we tell them to. This processing is necessary for the purposes of delivering specific services to you. You agree that we can share or use your personal data with any of our appointed agents or suppliers to allow us to provide you services and products you have asked us to provide you under this agreement, such as to facilitate delivery of your membership card or cards.
9.2 We may disclose your information to third parties, including the police and other governmental bodies, as required by law or if we think the disclosure may help to detect and deal with crime and unsavoury behaviour.
9.3 We may give your information to third parties to allow them to market their goods and services to you, but only with your express consent (please see above).
9.4 We will not sell your information to a third party, except in the unlikely event that we sell our business, or a substantial part of it; in which case we may sell your information as part of the sale to allow the purchaser to carry on providing some or all of our services to you.
Additional terms for this website
10. Do you have your own contact details page?
Soon after launch each member will be provided with access to a “Member Area” page on the site that will allow you to quickly and easily update your personal contact details and your preferences for the receipt of marketing communications.
11. Does the site provide tailored content?
The site aims to provide you with content, including adverts, tailored to meet your interests and needs based on your use of the site. Some of this content is provided by third party content providers, but you can rest assured that we do not provide your personal details to these providers as part of this service.
The following data is collected and stored by AltitudeCard.com until its automated deletion:
- IP address of the accessing computer/device
- Date,time and duration of your visit
- Name and URL of the accessed pages
- Identification data of the browser and operating system used
- Website from which the data was accessed
- Name of your internet access provider
The nature and content of the information collected via cookies differs, as does the period for which this information is retained. In line with our data protection obligations, we will ensure that this retention period is not excessive, and that the data is only retained for as long as is necessary for the purpose for which it was collected.
13. Can you see and update the information we hold about you?
Subject Access Requests
You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 inc. VAT when a request is manifestly unfounded, excessive or repetitive.
We will provide this information in a structured, commonly used and machine readable form such as a CSV file. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. Where possible, we will provide this information via remote access to a secure self-service system, such as our Customer Account area, which would provide you with direct access to your information.
If you would like to submit a Subject Access Request, please contact us via email at firstname.lastname@example.org and quote: Data Protection
We will response to your request without delay and at the latest, within one month of receipt of your request.
Rectifying or updating personal data
If you believe the personal data we hold about you is inaccurate or incomplete, you have the right to rectification. You can let us know about any changes to. Where possible, we will also inform any third parties to whom we have disclosed the personal data in question to so they can rectify their records.
We will typically respond to your request within one month.
You have the right to withdraw your consent for us to collect process and store your data at any time. If you wish to withdraw your consent, please confirm this via email to our Data Protection Officer
14. Do our privacy practices apply to disclosures you make to third parties?
Please note that this policy addresses only the use and disclosure of information we collect from you. If you give your information to others, whether they are third parties that we introduce you to or third party sites that you visit by clicking on a link on one of our web sites, different rules may apply to their use or disclosure of the information you give to them. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.
15. How can you contact us about privacy issues?
You can contact us about privacy issues or comment or complain about our privacy practices by contacting us at email@example.com.
Due to the further development of our website, government regulations or the implementations of new technologies, this policy will be reviewed, and may change, from time to time. AltitudeCard.com reserves the right to change this data protection information at any time with effect for the future. The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.